Privacy Notice/Statement
Introduction
AAA CK Life Pensions and Mortgages Limited trading as CK Financial Solutions is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of CK Financial Solutions in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
• CK Financial Solutions
• Contact details of CK Financial Solutions: email info@ckfinancials.ie
Telephone number 0449330729
• When we refer to ‘we’ it is CK Financial Solutions.
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Who are we?
AAA CK Life Pensions and Mortgages Limited acts as a Broker: Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, pensions, investments, mortgages and debt management.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
• Name: Declan Keegan
• Email address: info@ckfinancials.ie
• Phone number: 0449330729
Purpose for processing your data
o As a Broker, we collect and process your personal information to enable us to provide you with a product or service such as Life Assurance, Pension, Investment, Mortgage or Debt Management Service, and we rely on a number of legal bases for doing so including:
o To enter into and for the performance of a contract.
Application for a product or service
Ongoing product service reviews
o To comply with legal obligations
Assessing affordability and suitability for a product or service.
Responding to queries raised by regulatory authorities, law enforcement and or other government agencies such as Data Protection Commission, The Central Bank of Ireland, an Garda Siochana and the Revenue.
o Our legitimate business interests.
To enable us to manage our relationship with you including having readily available access to your information through use of IT systems and functionality.
o Where you have provided consent.
If you consented to marketing, we might use your personal information to make you aware of other products or services which we think could be of interest to you.
o Where you have provided us with information about another person.
Where you provided us with personal information relating to another person (e.g. partner, spouse or guarantor) we rely on you to ensure that you have their consent to providing us with their information for use in accordance with this Data Privacy Notice.
o To process on-line application forms submitted to us for the purposes of providing financial products. Any applications submitted on-line or by e-mail will be subject to the same terms and conditions as those completed by hand in paper form including additional terms and conditions relating to credit reference checking, money laundering and regulatory notices.
Why we are processing your data? Our legal basis.
In order to provide you with our services such as Life Assurance, Pensions, Investments, Mortgages and Debt Management, it is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) that we commit to delivering to you from time to time. Another legal basis is that some processing is necessary for the purposes of the legitimate interest that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm. There may also be circumstances where the legal basis for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.
In any event, CK Financial Solutions are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How will C K Financial Solutions use the personal data it collects about me?
CK Financial Solutions will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below
• we will obtain your explicit consent
Who are we sharing your data with?
We may have to share your personal data with the parties set out below for the purposes set out under the heading” Purpose for processing your data”.
• Service providers acting as processors based in the ROI who provide IT and system administration services.
• Professional advisers acting as processors including Insurance Companies, Asset Managers, Mortgage Providers and Insurers based in the ROI who provide pension, insurance, fund asset management, deposit and lending services.
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required in order to process an application or other communication from you or to perform the services that you have applied for. We will however disclose you Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
We may pass your personal data on to third-party service providers contracted to CK Financial Solutions in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with CK Financial Solutions procedures.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
We have issued all our third-party processors with a Data Processor checklist asking them GDPR specific questions
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Data Subjects Rights:
CK Financial Solutions facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling
• Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Additional information we are providing you with to ensure we are transparent and fair with our processing
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. CK Financial Solutions will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by CK Financial solutions or how your complaint has been handled, you have the right to lodge a complaint with CK Financial Solution’s data protection representatives Data Protection Officer.
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Canal House,
Station Road,
Portarlington,
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Web: www.dataprotection.ie
Email: info@dataprotection.ie
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
Profiling – automatic decision making
Profiling – automatic decision making
Profiling- Financial and mortgage advisors using profiling in their business. The main categories are
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product
a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
b) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
c) Establishing affordability and providing quotations for financial services products.
You can object to automatic decision making.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (0449330729 or email info@ckfinancials.ie
Privacy policy statement changes
CK Financial Solutions may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.
This privacy policy was last reviewed in March 2019
